2022 Communication on Progress

Sani Ikos Group

Published date

June 30, 2022

No. of questions

58

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    Annual ESG report

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    ESG report

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    For Labour and human rights those are all stated in the contract with all employees which is aligned with all legal requirements.

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    HR directror for Human and Labour rights. ESG director for environement and internal lawer for Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    HR directror for Human and Labour rights. ESG director for environement and internal lawer for Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    1. Most suppliers are evaluated with sustainability criteria 2. Business contracts are established for business relations 3. ISO 14001 risk assessment matrix is used

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Only if there is a case

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    7

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    Under 30 years old (%)

    30-50 years old (%)

    Above 50 years old (%)

    From minority or vulnerable groups (%)

    Executive (%)

    Independent (%)

    13. Do you produce sustainability reporting according to:

    Optional comment
    ESG REPORT

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    ISO 14064 for GHG
    Optional comment
    ISO 14001 assurance of environmental data , Travelife or Green key assures all sustainablity issues including HR related issues

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    Learning and development

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    The company has developed a training platform and various courses. Through the course all the related to work human rights issues are presented. Some courses like sustainability, antibribery, cyber security etc are mandatory. The company has a structured HR department which is dealing with all the labor related issues. Kpis are monitoring the performance of the department Finally for the reporting period a policy for discrimination and harressment has been developed.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    This is by law

    Forced labour

    This is by law

    Child labour

    Operating in EU countries, not relevant to business and regulated by the law

    Non-discrimination in respect of employment and occupation

    1/1/22 - Policy against violence and harassment in the workplace

    Occupational safety and health

    Legal risk registry, food safety procedures with ISO 22000

    Working conditions (wages, working hours)

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    No incidents occured so there was no need of such action | The group has a former employee union

    Forced labour

    No incidents occured so there was no need of such action | Forced labor n/a as this is regulated in the EU

    Child labour

    No incidents occured so there was no need of such action | No employees below 18 in any case

    Non-discrimination in respect of employment and occupation

    No incidents occured so there was no need of such action

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    1. As per law requirements with the risk assessment and measures. 2. All employeess recieve PPE and training on H&S risks 3. Internal and external audits also are taking place

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    As per law (operating in the EU) all labour issues are regulated by law. Forced labour / Child labour

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100
    Optional comment
    All the employees are covered under collective bargaining agreements .

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    100
    Optional comment
    the group has its own employee trade union

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    29

    Non-executive board

    44
    Optional comment
    44% refers to number of total employees per gender

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100
    Optional comment
    Equal pay depending on the jobs and responsibilities

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0
    Optional comment
    This relates to serious injures

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0
    Optional comment
    No serious uncidents reported

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    1. Internal and external H&S audits 2. Interviews with employees and annual satisfaction survey 3. Fully structured HR department to support Labour rights 4. Union

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2022 Strategy

    Water

    2022

    Oceans

    2021

    Forests / Biodiversity / Land Use

    2017

    Air Pollution

    Air Pollution is not under scope are are beach located hotel operators and no air emissions produced

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2013

    Energy & Resource Use

    2019
    Optional comment
    ESG REPORT https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    ESG report https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    n/a

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Materiality analysis conducted and presented to the ESG report https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    n/a

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    1. Sustainability training is provided to all employees 2. We are working with NGOs and institutes like iSea and Forest resarch institute on Carbon and Ocean issues 3. External audits like ISO 14001 audit our sustainability program 4. We are complying with all related regulations. ESG report https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    n/a

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    ISO 14001 / 50001 / 14064 and ESG targets in place. We are setting annual targets/ goals and track progress with internal and external audits. ESG report https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    All electricity powering our hotels is coming from RES with GOs. Sani is Carbon neutral certified with ISO 14064 since 2020 and all Ikos resorts to be certified for 2021 operations. An action plan is underway to electrify all kitchens, as well as our fleet, and install electric car chargers across the resorts, to meet our Net Zero 2030 target.

    Energy & Resource Use

    1. Energy reduction by 2,5% every year for the next three years 2. To get ISO 50001 certification within 2022 3. We have placed meters and submeters and an EMS system

    Water

    We are monitoring water consumption on a daily basis. We have place flow restrictors in order to reduce the water consumption in guest areas. All waste water is treated and used for irrigation at a level of 100%

    Forests / Biodiversity / Land Use

    Biodiversity is at the centre of Sani/Ikos Group operations. The Group implements a series of actions with the aim to preserve, protect and enhance the environment. In partnership with the Hellenic Ornithological Society (HOS) and Birdlife we are working on the Sani Wetlands project which focuses on biodiversity protection and education. With an area of approximately 110 hectares, the wetlands are home to over 225 species of bird.

    Air Pollution

    All water water burners are controlled for emissions on a monthly basis. Air pollution is not significant and material issue

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    All waste is managed with licensed suppliers. Waste management is reported monthly . ESG report with annual results in place

    Oceans

    1. No plastics are used frontline in our hotels within the group 2. Working with NGO Isea on a project which aims to inform school-aged children about marine mammals and the value of the local marine environmen 3. All beaches are Blue Flag certified
    Optional comment
    2021 ESG report describes in details all the above https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    No actual negative impacts occured

    Water

    No actual negative impacts occured | Biological treatment plant is operated within the govermental limtis

    Oceans

    No actual negative impacts occured | All water analysis are complying the EU directive regading bathing profile at excellent values

    Forests / Biodiversity / Land Use

    No actual negative impacts occured

    Air Pollution

    No actual negative impacts occured

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    No actual negative impacts occured | all waste produced is managed accoring to legislation at high levels of recycling and all hazardous waste is treated as per EU legislation

    Energy & Resource Use

    No actual negative impacts occured
    Optional comment
    No actual negative impacts occured

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    5165.18

    Scope 2 Emissions

    Emissions (tCO2e)

    269.98

    Scope 3 Emissions

    Emissions (tCO2e)

    Optional comment
    Not reported for 2021

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    Optional comment
    Not calculated specifically. 1. Capex expenses are evaluated against sustainability criteria (energy efficiency, low carbon etc) . 2. All new cars are electric or plug in hybrid. 3. All electricity used is RES certified with GOs

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    97
    Optional comment
    GOs

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    100
    All the hotels of the group are ISO 14001 and GSTC certified s third-party certified to environmental and/or social sustainability standards

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    861

    Groundwater:

    861

    Surface water:

    0

    Rainwater:

    0

    Wastewater:

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    861

    Groundwater:

    861

    Surface water:

    0

    Rainwater:

    0

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    Optional comment
    All the waste water is treated and the waste water produced (after the third stage of biological treatment plant and UV) is used for irrigation.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Optional comment
    Groups is operating in regions with no extemely high water stress.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    All actions are reported to the ESG report https://cms.sani-resort.com/media/5aqmohs5/sani-resort-ikos-resorts-2020-final-esg-report_-february-2022.pdf

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2022
    Optional comment
    Anti-Bribery, Anti-Corruption & AML Policy

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Anti-Bribery, Anti-Corruption & AML Policy

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    Mandatory training to the training platform

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    All new employees must do the training as a mandatory training.

    4. Does the company monitor its anti-corruption compliance programme?

    Optional comment
    Internal employee and extrnal DPO for GDPR issues

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    0

    Confirmed during the current year, and related to this year

    2021
    0

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    Optional comment
    no incidents in the reporting period

    7. Does your company engage in Collective Action against corruption?

    Anti bribery policy in place and mandatory training for all employees.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    1. Policy in place 2. Mandatory training for all employees (online training)